Home Case Index All Cases Income Tax Income Tax + AT Income Tax - 2012 (10) TMI AT This
Forgot password New User/ Regiser ⇒ Register to get Live Demo
2012 (10) TMI 437 - AT - Income TaxValidity of re-opening of assessment u/s 147/148 - research and development expenditure - dis-allowance of technical assistance fee paid as capital in nature - Held that:- It is seen that the assessee was asked to furnish the details of Research & Development expenses and the complete details including the break-up were provided by the assessee in the original assessment which was completed after considering the details and the reply of the assessee. Thus, it is seen that the facts and issue involved in the present year of appeal are identical to the facts and issue involved in AY 2001-02 wherein the Tribunal has confirmed the order of the CIT(A) holding the re-assessment proceedings as invalid. Respectfully following the same, in the present year of appeal also, re-assessment proceedings are held to be invalid - Decided in favor of assessee
|